Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporations: Line-by-Line

Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Tuesday, April 25, 2023

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, March 31, 2023

or call 1-800-926-7926

This course will provide tax advisers with a practical, in-depth guide to completing Form 5471's recently revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed in the various sub-sections of IRC 959, and detail how to identify the Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income required in Part II. This is an advanced level webinar for attendees well versed in prior revisions of Form 5471.

Description

The complexity and compliance burden of virtually all foreign tax information reporting continues to escalate. Multiple provisions in the law increased the calculation, payment, and reporting obligations on U.S. taxpayers with foreign income or assets and foreign taxpayers with activities subject to U.S. tax jurisdiction. These forms continue to be updated and modified annually.

Form 5471 continues to be one of the most complicated reporting obligations in the U.S. offshore information tax reporting regime, notably Schedule J, Accumulated Earnings and Profits (E&P) of Controlled Foreign Corporations. However, the deemed repatriation provisions necessitated a modification of Schedule J, involving a longer and significantly more complicated set of calculations.

Schedule J contains additional categories of accumulated E&P with requirements to calculate and disclose reclassifications within various sub-sections of IRC 959. The Schedule also contains an additional part and several new columns requiring taxpayers to report current and recaptured Subpart F income. These calculations create additional burdens to an already complex form.

Listen as our panel of veteran advisers provides an in-depth, line-by-line, and column-by-column guide to the changes tax reform made to completing Schedule J.

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Outline

  1. Prior versions of Schedule J
    1. Seven (7) lines of calculations
    2. Five (5) columns of income/E&P classifications
    3. All references to post-1986 balances and carry-forward amounts
  2. Income classifications in revised Schedule J
  3. Calculation questions
  4. Part II Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (Section 952(c)(2))

Benefits

The panel will discuss these and other specific changes to Schedule J:

  • Lines and columns required to report accumulated E&P balances concerning categories of previously taxed E&P necessitated by income inclusions under Section 965(a) and GILTI
  • How this schedule incorporates Subpart F inclusions and recaptures
  • How to handle deficit calculations after nonrecognition transactions
  • Reclassification lines
  • Changes made to Schedule J for the current year

Faculty

Diosdi, Anthony
Anthony V. Diosdi

Partner
Diosdi Ching & Liu

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax...  |  Read More

Dougherty, Alison
Alison N. Dougherty, CPA

Managing Member
Googolplex Tax Services

Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and...  |  Read More

Attend on April 25

Early Discount (through 03/31/23)

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Early Discount (through 03/31/23)

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